Professor Bev John and Professor Gareth Roderique-Davies – Written evidence (GAM0023)


  1. We are submitting this evidence in an individual capacity based on our professional expertise and experience. We are HCPC-Registered Health Psychologists and we co-lead the Addictions Research Group at the University of South Wales. We are invited observers of the Cross-Party Group on Problem Gambling at the National Assembly for Wales and sit on the “Beat the Odds” steering group that is run by Cais Ltd. We have received funding to undertake research into the social impact of gambling in Wales from the personal research budgets of the following Assembly Members: Mick Antoniw, AM; Jayne Bryant, AM; Lesley Griffiths, AM; Jane Hutt, AM; Jenny Rathbone, AM and Ken Skates, AM. We declare that we have no conflicts of interest in providing this written evidence.


  1. The Gambling Act 2005 (Question 1). It is our opinion that the Gambling Act 2005 aim to protect children and other vulnerable persons from being harmed or exploited by gambling is not being upheld. Evidence from both the UK[1] and Australia[2] suggests that gambling advertising on television and social media captures the attention of young people and has an impact on their behaviour. It was recently reported that in Great Britain, 14% of children aged 11-16 have gambled in the past week, with around 55000 reporting problems from their gambling behaviour[3].


  1. The Gambling Act 2005 (Question 1). Our research[4] has identified the indirect impact on children of having parents with gambling problems, including financial hardship and living with the threat of homelessness, and also early initiation into the gambling world.


  1. Social and Economic Impact (Question 5). Our research4 identified the negative social and health impacts of gambling from a number of personal accounts provided. These include personal struggles and despair, family breakdown, poverty and growing up with the threat of homelessness.


  1. Social and Economic Impact (Question 5). Our research4 identified that gambling is a hidden problem in a number of ways: It carries stigma for both the gambler and family. Individuals are very reluctant to admit to gambling problems. The majority of people gamble alone, and the exponential increase in access to gambling via websites, as well as phone and tablet apps increases the solitary nature of gambling, and the difficulties in computing actual prevalence. Alcohol consumption appears to exacerbate these factors. The lack of specialist services means that there are no databases of individuals with problem and dependent gambling. Proxy services where these individuals may present (e.g. debt and addiction services) do not, for the most part, screen for gambling problems and there is no systematic identification of need.


  1. Levy (Question 7). The voluntary levy is not adequate to meet current needs for research, education and treatment for a number of reasons. Firstly, there is a paucity of treatment services for what is a growing public health problem. Our research4 indicates that problem gamblers present at non-gambling services (for example related to financial difficulties). Service providers tend to pick up on gambling problems ‘intuitively’ rather than systematically. These come to light when discussing individuals’ budgeting plans, and when discrepancies can be seen between income, outgoings and debt problems. Where gambling problems are identified, service providers are unsure to whom to refer clients.


  1. Levy (Question 7). Secondly, the majority of gambling-related research funding is provided by GambleAware. There is a perception (rightly or wrongly) amongst many academic researchers that the organisation is not truly independent and as such will not apply for funding.


  1. Levy (Question 7). Thirdly, significant concerns remain given the voluntary nature of the levy. Since gambling companies are not told how much to contribute or even to which organisation they contribute, voluntary donations can be perceived as both good marketing where it does occur and also as having strings attached. The voluntary nature of the Levy, and as such the uncertainty over income, does not facilitate the long-term planning of treatment, research or educational programmes.


  1. Levy (Question 7). Recommendation: A public-health approach should be adopted. Research, education and treatment funding should be met by a mandatory and industry-wide tax or levy. Research and Education funding should be administered by an independent organisation free from industry and political influence. Funds allocated to treatment should be distributed via the NHS.


  1. Research (Question 8). Recommendation: The quality of research can be improved by the administration of funding by an independent organisation as referred to in paragraph 9. Funding should be distributed in accordance with a national strategy (devised by an independent board) according to standards that are shared by all academic research (e.g. competitive calls, academic rigour and accountability, impact and public engagement, input from experts by experience, implementation and dissemination, open access publishing).
  2. Research (Question 9). The situation can be addressed by an independent funding organisation ring-fencing funding for this purpose in line with the principles outlined in paragraph 10.


  1. Advertising (Question 13). We agree with the statement that by taking no action to limit the exposure of young people to gambling advertising “we are in danger of inadvertently conducting an uncontrolled social experiment on today’s youth, the outcome of which is uncertain but could be significant. In addition to the studies referred to in paragraph 2 suggesting that gambling advertising on television and social media captures the attention of young people and has an impact on their behaviour1,2, our research uncovered negative perceptions of respondents to gambling advertising. Perceptions in relation to exploitation, manipulation and anger were expressed at what is seen as a deliberate targeting of the poor both in making gambling accessible, and through aspirational advertising that creates false hope4.


  1. Advertising (Question 13). Our research suggests that students appear to be a vulnerable population with two broad groups of students particularly susceptible to developing gambling problems. These are students studying for sports qualifications and students who struggle socially, and have difficulty developing friendship groups4. The observation was made by a student services advisor that sports students tend to bet more on sporting events: ‘I have noticed that sports students are particularly at risk. A lot of ads target themwe’ve noticed it’s quite prolific in sports students.’


  1. Gambling and sport (Question 14). The association between gambling and sport mirrors strategies previously implemented by both the tobacco and alcohol industries. We have recently found evidence that embedded gambling advertising (such as shirt sponsorship) increases the urge to gamble[5] and, following on from paragraph 14, that sports students are more susceptible to this. We suggest that this is a consequence of the integral nature of sport and gambling such that gambling is seen as a part of sport rather than an adjunct.


  1. Gambling and sport (Question 14). While we are seeing attempts to curtail the negative impact of gambling advertising upon young and vulnerable audiences during televised sports (such as the “whistle-to-whistle” ban on gambling advertising), this does not encompass more nuanced forms of advertising such as embedded promotion. Critics of embedded promotion suggest that it is a subtle and deceptive assimilation into live screen-time[6]. Recommendation: That gambling advertising and promotion be subject to similar legislative restrictions to tobacco in relation to sport.


  1. Lotteries (Question 19). Our research4 has found that the most common form of gambling activity reported by respondents were National Lottery games. However, there was a disparity between individuals reporting that they played National Lottery games and reporting that they gambled, which indicated that many consumers did not consider National Lottery games to be a form of gambling. Recommendation: Any changes to the statutory regime governing the National Lottery and other lotteries should ensure that their status as gambling activities is clear to consumers.


5 September 2019

[1] Djohari, N. et al (2019). Recall and awareness of gambling advertising and sponsorship in sport in the UK: a study of young people and adults. Harm Reduction Journal, 16(24), pp. 1-12

[2] Thomas, S. L. et al. (2016). Child and parent recall of gambling sponsorship in Australian sport. Victorian responsible gambling foundation; Nyemcsok, C. et al. (2018). Young people’s recall and perceptions of gambling advertising and intentions to gamble on sport. Journal of Behavioural Addictions, 7(4), 1068-1078.

[3] Wardle, H., et al. (2019). Gambling and public health: we need policy action to prevent harm BMJ, 365: l1807.

[4] John et al (2017). An Investigation of the social impact of problem gambling in Wales. Welsh Assembly Members Consortium / USW (

[5] Roderique-Davies, G. et al (unpublished) Embedded Gambling Promotion in Football: An Explorative Study of Cue-Exposure and Urge to Gamble. Currently under review in an academic journal.

[6] Castrén, S., et al (2018). Association between gambling harms and game types: Finnish population study. International Gambling Studies, 18(1), 124-142.